Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT upheld the order of CIT(A)/NFAC sustaining taxability of long-term capital gains u/s 112 on sale of immovable properties by the assessee. The assessee had not disclosed the capital gains in the return filed u/s 139, claiming the lands were agricultural and thus not taxable as capital assets. CIT(A)/NFAC found no credible, authenticated evidence of agricultural use after purchase in 2008, and noted the substantial price appreciation by 2012 as inconsistent with claimed agricultural character. Finding no contrary material, ITAT dismissed the assessee's appeal and confirmed the assessment.
ITAT upheld the order of CIT(A)/NFAC sustaining taxability of long-term capital gains u/s 112 on sale of immovable properties by the assessee. The assessee had not disclosed the capital gains in the return filed u/s 139, claiming the lands were agricultural and thus not taxable as capital assets. CIT(A)/NFAC found no credible, authenticated evidence of agricultural use after purchase in 2008, and noted the substantial price appreciation by 2012 as inconsistent with claimed agricultural character. Finding no contrary material, ITAT dismissed the assessee's appeal and confirmed the assessment.
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